ITO Section 46

Profit on debt. 

Any profit received by a non-resident person on a security issued by a resident person shall be exempt from tax under this Ordinance where—

• (a) the persons are not associates;
• (b) the security was widely issued by the resident person outside Pakistan for the purposes of raising a loan outside Pakistan for use in a business carried on by the person in Pakistan;
• (c) the profit was paid outside Pakistan; and
• (d) the security is approved by the 1[Board] for the purposes of this section.